VAT Ruling No. 033-93

May 19, 1993 VAT RULING NO. 033-93 Section 2-80 102-92 033-93 Kodak Philippines, Ltd. 1258 Makati Metro Manila Attention: Ms . Arlene C . Artillero Accounting Supervisor S i r s : This is with reference to your letter dated November 23, 1992 stating that your company supplied animation cells and motion picture negative films to Moving Images International, Inc. and Philippine Animation Studio, Inc.; both are BOI registered companies exporting 100% of their products; and that said animation calls and motion picture negative films are to form part of the finished products to be exported by both companies. Based on the foregoing, you now request for a ruling on whether or not your sales of animation cells and motion picture negative films to Moving Images International, Inc. and Philippine Animation Studio, Inc. are zero-rated. cdll In reply, please be informed that since the animation cells and motion picture negative films your company sold to Moving Images International, Inc. and Philippine Animation Studio, Inc. qualify as raw materials which shall form part of the finished products to be exported, said sales shall be subject to zero-rate VAT in accordance with Section 2 of Revenue Regulations No. 2-88. Very truly yours, JOSE U. ONG Commissioner of Internal Revenue